food safety standards –equivalent or not · •iso 22000:2005 •….. which to ... •records to...

Food safety Food safety

standardsstandards

–– equivalent or equivalent or

notnot

LINDA JACKSON

[email protected]

South Africa

IAFP EUROPE 2008, LISBONIAFP EUROPE 2008, LISBON

Spot testSpot test……..

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•• DirectDirect

•• ........

What is the objective of food What is the objective of food

safety management safety management

systems?(FSMSsystems?(FSMS))

• Safe foodFood that does not cause harm to the

consumer

when it is prepared and / or eaten according

to

its intended use

• How do we manage the risks to ensure safe food?

OptionsOptions

• Several standards available• Regulatory and Statutory requirements

• Private schemes• BRC Global standard

• SQF 2000

• Dutch HACCP standard

• International Food standard

• AIB standard

• NSF

• ISO 22000:2005

• …..

Which to choose?Which to choose?

• Customer selects for you?

• Cost of implementation?

• The best standard for safe food?

• Cost of audit?

• Easiest audit?

• Politics?A bit like my travel

plans…

GFSIGFSI

• Facilitated by CIESnet – The Food Business Forum

• Food safety is a non-competitive issue• Key priorities• To implement a scheme to benchmark food safety standards worldwide

• To build and implement an early warning system• To encourage co-operation between governments and authorities

• To communicate and promote consumer education• To co-ordinate Good Retailing Practices• “Once certified, accepted everywhere”

GFSIGFSI

• Key elements • Food safety management systems

• GMP, GDP, GAP

• HACCP

• Compliant standards• BRC Global Food Standard

• Dutch HACCP Code

• SQF 1000 and 2000

• International Standard for Auditing Food Suppliers

BRC Global standard BRC Global standard ––

FoodFood

• Introduced in 1998

• Attempt to reduce the number of technical audits for suppliers

• 8067 certificates in 2007

• All British retailers????

IFSIFS

• German retail standard

• Published in 2002

• Now accepted by French, Italian and Polish retailers

• 8414 certificates in 2007

SQF SQF

• Owned by Food Marketing Institute, USA

• Originated in Western Australia in 1995

• “Over” 8000 certificates in 2007

• Level 3 recognised by GFSI

ISO 22000:2005ISO 22000:2005

• Danish recognise that ISO 9001 is not sufficient for food safety

• Request ISO to develop an international standard• November 2001 critique existing standards by 8 countries

• November 2004 review involved 17 countries• Voting November 38 countries approved, 3 rejected• Published September 2005• NOT GFSI recognised• Over 4000 companies in 93 countries in 2007(ISO)

Reaction to ISO 22000Reaction to ISO 22000

• GFSI• “Does not facilitate on-site inspections’ – best manufacturing practices/PRP’s not adequately covered?

• Additional document – PAS 2200 must be used to audit in conjunction

• Areas of difference include accreditation process, ownership – liability, slow process to change the standard

• Difficult for retailer to accept as equivalent, no reason why a company can’t work to ISO 22000 whilst maintaining certification to a private recognised standard

• BRC• “Tailor-made”• Due diligence better covered

• Other retailers…

GFSIGFSI

Standard BRC Global

standard –

Dutch

HACCP

Code

Option B

SQF 2000

Level 3

Level 2???

IFS ISO 22000

Not yet

GFSI

compliantPublished 1998 1995 1994 2002 2005

Certificates

issued 2007

8067 “Over” 2000 “Over” 8000 8414 “Over” 4000

Used by All British

retailers?

Dutch

retailers?

American

retailers?

Australian

retailers?

German,

French,

Italian and

Polish

retailers

93 countries

Not all food

processors

Other Developed

by the

retailers to

reduce

number of

audits

Developed

by Dutch

National

Board of

Experts

Acquired by

FMI in 2003,

originated in

Western

Australia

Developed

by German

retailers

Will require

PAS

2200:2008

to be used

in

conjunction

during audit

GFSIGFSI

““Once certified, Once certified,

accepted accepted

everywhereeverywhere””

Reaction to private Reaction to private

schemesschemes

Pro’s

•“Reduce multiple audits”

•“Taking ownership of product integrity for

private label”

•“Recommendation:

Accept certification

to all GFSI

standards”

•“Simpler buying”

Cons

•Trade barriers?

•“Untransparent”

•“ Not science-based”

•Equivalence – no such thing! - Customer is king

•Why go beyond legal compliance?

•Added cost to supplier

StrengthsStrengths

ISO 22000 BRC SQF

Strong focus on the

development of a HACCP

system

Improved focus on HACCP

in version 5

Well defined PRP’s

Well defined requirements

for communication

Pre-requisite programmes

clearly described

More guidance than BRC

on facility requirements,

better than PAS 2200

Scope includes support

industries to the food

manufacturing sector

Incident management

clearly defined

Strong focus on business

continuity planning and site

security

Objectives intended to

integrate food safety as a

business activity

Control of operations

highlights the need for food

safety to have daily focus

Validation of PRP’s

required

Address laboratory testing

of product

Allows for a progressive

approach to system

development with

recognition at each level.

WeaknessesWeaknesses

ISO 22000 BRC SQF

No specific requirements

for adequacy of PRP’s –

read between the lines…

Some fundamental

requirements overstated.

Fundamental requirements

imply certain requirements

of secondary importance

HACCP requirements one

page – even less than

Codex...

Tone of the standard does

not promote understanding

that FSMS should be

maintained

Preventive action not

defined

Preventive action not

defined

Day to day process control

related to food safety

omitted

Quality aspects may dilute

the focus on food safety

Requires a certified SQF

practitioner involvement –

extra cost?

Overview and comparisonOverview and comparison

REQUIREMENT ISO 22000 BRC SQF

Food safety policy 5.2 3.1 4.1.1

All require review

and continual

improvement

Business

objectives

Communication

Food safety and

quality objectives

Responsibility and

authority

5.4 3.3 4.1.2

Defined and

communicated

responsibilities.

Food safety only

All personnel

have

responsibility to

report problems

with food safety

Organisation chart

Key cover

Documented

responsibilities for

food safety,

quality and

legality

General duties for

ALL staff

Organisation chart

Key cover

Job descriptions

Management requirementsManagement requirements



Food safety team

leader

5.5 2.1.2 4.1.2.2

Manage food

safety team,

report to top

management

HACCP team

activities only

Communication

Lead

development of

system

Validation

VerificationCommunication 5.6 1.2

3.4.1

3.11

4.1.2.2

4.1.6

Defined focus for

communication

requirements

Not as extensively

covered

Not as extensively

covered




Management

review

5.8 1.5-1.9 4.1.4

Senior

management in all

cases

Continued

suitability and

effectiveness of

the FSM system

•Changes,

Emergencies,

objectives, audits,

customer

feedback

•Specifies

requirements for

records

Critical evaluation

of the Food safety

plan and HACCP

system

effectiveness

•Records to be

updated on

completion of

actions

Policies

Internal audit

findings

Corrective actions

Customer

complaints

Annually


Audit criteriaAudit criteria

REQUIREMENT ISO 22000 BRC Version 5 SQF 2000 version 6

Management responsibility 5 1 4.1

Human resources 6.2 7.1 4.1.2.2

Pre-requisite programmes 7.2 4,5,7 4.4.2, 6

Preliminary steps to enable

hazard analysis

7.3 2.1-2.5 9

Hazard analysis 7.4 2.6 9

OPRP’s 7.5

HACCP plan 7.6 2.7-2.12 4.4.3

Verification planning 7.8 2.11 4.5.1

4.5.6

Traceability 7.9 3.9 4.6.2

Control of nonconformity 7.10 7.10.2 5.6 – all products 4.4.7(all products)

Validation 8.2 2.8.3 4.1.4.4

4.5.2

Control of measuring and

monitoring

8.3 6.3 6.4

FSMS verification 8.4 2.11 4.5.1

4.5.3.1

4.5.4

Internal audit 8.4.1 3.5 4.5.5

Audit criteriaAudit criteriaREQUIREMENT ISO 22000 BRC

Version

5

SQF 2000

version 6

Contract service

providers

4.3.4

Incoming material

requirements

5.3 4.12 Incoming goods and

services

4.4.5

4.2 Site security 4.7

Personal hygiene

Training

7

10

Access control

Personnel hygiene

7 Personnel practices 6.1

Maintenance and

cleaning

Cleaning programmes

6.1

6.2

Housekeeping and

hygiene

4.9 Cleaning and sanitation 6.7

Physical and chemical

contamination

5.2.5 Chemical and

physical product

contamination

control

4.8.3

4.8.4

5.3

Control of physical

contaminants

6.9

Purchasing 3.6 Supplier approval 6.10

Materials containing

allergen

5.2.1 Allergen control 6.13

Control of operations 5.2 Process control 6

PAS 2200:2008 not yet published, Codex Alimentarius

CAC/RCP 1-1969, Rev. 4 (2003)

PARTIAL AUDIT

Results of the auditsResults of the audits

• Could you pass one and fail another?• Yes and no...


• BRC• Non-conformances linked to the “intent” of the requirements, particularly Fundamentals

• SQF• Nonconformances linked to food safety risk

• ISO 22000• Nonconformances linked to conformance to the requirements

• All requirements carry equal weighting


• BRC• Nonconformances relating to HACCP caused failure

• SQF• HACCP requirements would suffice

• ISO 22000• Nonconformances relating to Hazard analysis caused failure


• BRC• Failure for• Current issue of standard not being available

• Planning of re-certification

• Senior management not at opening meeting

• SQF• No findings – 60 day window

• ISO 22000• No findings – certificate automatically suspended without audit

Analysis of audit resultsAnalysis of audit results

• BRC• Nonconformances relating to HACCP caused failure for BRC certified companies

• Nonconformances relating to HACCP and PRP’s caused failure for non-certified

companies

• SQF• Existing HACCP requirements would suffice

• Any HACCP plan would do…

• ISO 22000• Nonconformances relating to detail of Hazard analysis caused failure

Summary of the standard Summary of the standard

structurestructure

MANAGEMENT

SYSTEM

HACCP

PRP

BRCBRC

MANAGEMENT

SYSTEM

HACCP

PRP

ISO 22000ISO 22000

MANAGEMENT

SYSTEM

HACCP

PRP

SQFSQFSQF

Auditing requirementsAuditing requirements

• Accreditation requirements

• Auditor competence requirements

• Audit scope – multi-site implications?

• Audit duration

• Audit frequency – increase/decrease

• Audit outcome – major/minor/critical

• Grading outcome – does this foster the wrong approach?

• Corrective action – time frames

• Audit costs

What provides safe food?What provides safe food?

• HACCP?

• Pre-requisite programmes?• All equally important in all cases?

• Management commitment?

• Quality?

ConclusionsConclusions

• The devil is in the detail?

• The “have to have’s” versus the “nice to have’s”?

• Is the content sufficient guidance for developing countries?

• Conformance vs. “compliance” –implied vs. precribed?

ConclusionsConclusions

• Auditor interpretation can still influence the outcome

• Auditor competence can create havoc...

• Any improvement is better than none!

• Best practice should not be confused with “one-upmanship”….

• Mandatory review results in more stringent requirements but does

Acknowledgements

•• Rymco AfricaRymco Africa

•• Paarl Valley BottlersPaarl Valley Bottlers

•• Lancewood CheeseLancewood Cheese

•• QK MeatsQK Meats

•• Kees Beyers ChocolatesKees Beyers Chocolates

•• The Coca Cola The Coca Cola

CompanyCompany

Thank you for your Thank you for your

attentionattention

Contact details

•• [email protected]@vonholyconsulting.c

omom

•• VON HOLY CONSULTINGVON HOLY CONSULTING

•• PO BOX 4449 PO BOX 4449

EDENVALE 1610, EDENVALE 1610,

GAUTENG, RSAGAUTENG, RSA

•• +27114528014+27114528014

food safety standards –equivalent or not · •iso 22000:2005 •….. which to ... •records to...

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